There are a few basic principles of law that apply to all criminal cases. The
first is the presumption of innocence. Every defendant in a criminal case is
presumed to be innocent; this presumption of innocence remains with the
defendant throughout the trial unless and until the state proves beyond a
reasonable doubt the elements of the crime charged. The defendant does not have
to prove that (he/she) is innocent.

The burden of proof is on the state to prove beyond a reasonable doubt the
elements of a crime charged under a count before you can find the defendant
guilty of that crime. In my later instructions to you I will fully explain what
is meant by burden of proof and proof beyond a reasonable doubt. I will also
explain the elements of each crime charged.

Every defendant in a criminal case has the right not to testify if (he/she)
so chooses. This is a right guaranteed by the constitution of the United States
and the constitution of Connecticut. If, in this case, the defendant does not
testify, you must draw no unfavorable inferences from the defendant's failure to
testify.